Iowa Orthopaedic Society

Antitrust Compliance Policies and Procedures  

The Iowa Orthopaedic Society has a policy of strict compliance with federal and state antitrust laws, rules and regulations. Therefore:


  1. These Compliance Policies and Procedures apply to all membership, board, committees and other meetings sponsored by the Iowa Orthopaedic Society and to all meetings attended by representatives of the Iowa Orthopaedic Society.

  2. Iowa Orthopaedic Society members cannot come to understandings, make agreement, or otherwise concur on positions or activities that in any way might (i) influence price, such as cost of goods, operations, supplies, labor or services; allowances for discounts; and profit margins and mark-ups, provided that this limitation shall not extend to discussions of methods of operation, maintenance and similar matters in which cost or efficiency is merely incidental; or (ii) tend to raise, lower or stabilize prices or fees. Iowa Orthopaedic Society members also cannot discuss terms of sale, including credit arrangements. Members can discuss historical pricing activities, so long as information is general in nature and does not include data on current or future fees being charged, or other terms and conditions that may lead to agreement on what constitutes a reasonable, fair or appropriate price or fee to charge for a service or product in any trade area. A price-fixing violation may be inferred from price-related discussions followed by parallel decisions on pricing by Iowa Orthopaedic Society members – even in the absence of an oral or written agreement.

  3. It is a violation of antitrust laws to agree not to compete. Therefore, discussions of division of territories or patients or limitations on the nature of business carried on or products sold are not permitted.

  4. Boycotts in any form are unlawful. Discussion relating to boycotts is prohibited, including discussions about blacklisting or unfavorable reports about particular companies, including their financial situation.

  5. It is the Iowa Orthopaedic Society’s policy that Society representatives (i.e., staff, members, volunteers or elected officials) shall not participate in or condone anticompetitive communication among members. If an Iowa Orthopaedic Society representative is a participant in any meeting or in any communication that borders on an area of antitrust sensitivity, the Society’s representative may request that the discussion be stopped and ask that the request be made a part of the minutes of the meeting being attended. If others present continue such discussions, the Society’s representative should excuse himself or herself from the meeting and request that the minutes show that s/he left the meeting at that point and why s/he left. Any such instances should be reported immediately to the President and staff of the Society.

  6. It is the policy of the Iowa Orthopaedic Society that a copy of these Antitrust Compliance Policies and Procedures be given to each officer, director, committee member, official representative or member companies and Society employees and agents annually and that the same be read or reviewed at all meetings of the membership of the Society. In addition, these Policies and Procedures shall be maintained and available at all times on the Society’s website.